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PRIVACY POLICY

PURSUANT TO ART. 13 OF LEG. DECREE 196/2003

(Personal Data Protection Code )

Foreword D.LGS 196/2003 (Personal Data Protection Code) governs the processing of personal data. “Data processing” is intended as “any operation or set of operations carried out with or without the aid of electronic instruments, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, the cancellation and destruction of personal data even if not registered in a database." As a general rule, the law requires that the data subject gives his/her consent to the processing. Also, the data subject has the right to obtain information regarding personal data, explained more in detail hereafter.

Purposes of data processing The Owner of this Website informs you that the data provided by the data subject, acquired directly from the same in the past either verbally, or through third parties, or that may be requested or disclosed in the future by the same data subject or by third parties, may be processed also by third party companies designated as Data Processors, for the following purposes:

Accounting, administrative, fiscal purposes etc, in compliance with the obligations foreseen by the relevant laws, provisions and EU regulations, or by the provisions laid down by authorised Bodies and Supervisory Bodies. The submission of personal data for such purposes is mandatory and prior consent to their processing is not required from the data subject. Refusal by the data subject to confer personal data shall prevent all commercial relationships with the Website Owner.

Purposes strictly related and instrumental to the management of clients’ contract relationships either existing or underway, for example: acquisition of information prior to the execution of a contract, execution of operations on the basis of obligations arising from contracts entered into with clients, verification and assessment of results and relationship progress, as well as all the risks implied. Data subject is not obliged to confer personal data for such purposes, but refusal to do so may render the service request impossible, with regards to the relation between the data and the service required. In case such data is conferred, it can be processed without the consent of the data subject.

Purposes related to activities carried out by the Website Owner, including:

Measurement of customer satisfaction levels with regard to the quality of the services provided and the Website Owner’s activities through phone interviews, personal interviews questionnaires, etc.

Promotion and sale of products and services supplied by the Website Owner or by third party companies through mail, telephone, promotional material, automated communication systems, etc.

The supply of personal data for such purposes is optional. However, if provided, the data subject must also give his/her consent to their processing.

Data processing modes

Instruments and logics applied.

In relation to the purposes mentioned above, personal data will be processed manually or using IT or web tools relying on logics that are strictly related to the purposes for which they were gathered and in such a manner as to ensure the security and confidentiality of your personal data. The data subject agrees to promptly notify the Website Owner of any correction, changes or updates to the said data. Personal data may be processed on behalf of the Website Owner - for the purposes and through the modes mentioned above and in compliance with suitable criteria for ensuring safety and confidentially with respect to such data - also by companies, authorities and outsource collaborators designated as “Data Processors” and only within the scope of such data processing activities.

Duration.

Personal data shall be kept for the whole duration of the contractual relationship.

After that, they may be processed for fulfilling legal obligations and for marketing purposes.

Sensible data.

None of your personal data, either required or already in our possession, can be classified as “sensible data” or “judicial data”, as laid out under letters d) and e) of art. 4 of Leg. Decree 196/2003. In case you supply data of such nature, in the absence of your express written consent, we shall immediately proceed to cancel them from our database.

Subjects to whom personal data can be disclosed or with which they may become acquainted in their capacity of Data Controllers or Data Processors within the scope of disclosure of such data.

Foreword: Your personal data shall not be disclosed for any purpose, including consultation purposes.

The Website Owner may disclose personal data without the express consent of the data subject, to any third party for which such disclosure is required by law, by provisions or EU regulations.

The Website Owner may also disclose such data, with the explicit consent of the data subject, to companies, offices, authorities and outsource collaborators appointed to carry out on his/her behalf data processing activities related to the purposes mentioned under point 2 and 3, section A. The data subject has the right to be informed about any subject to whom personal data may be disclosed and can exercise such right through a simple request made to the Data Controller, as per point E.

The following categories of individuals, referred to under points B 1) and C 2), are entitled, in their capacity as Data Controllers and Data Processors, to access your personal data for purposes strictly related to their assigned duties: website owner staff workers, project - based contract workers, temporary contract workers, apprentices, consultants, external staff working at Website Owner’s premises, staff belonging to outsource companies appointed as Data Processors.

Rights of data subject

Pursuant to art. 7 of Leg. Decree 196/203, the data subject is entitled to exercise specific rights related to the processing of personal data. Below is the text of art.7:

The data subject has the right to obtain confirmation about the existence of personal data concerning him/her, even if such data has yet been recorded, as well as the communication of such data in an intelligible form.

The data subject has the right to be informed about: a) the origin of personal data; b) the purposes and processing mode; c) the logic applied to data processing if carried out with the aid of electronic means;

d) identification data concerning data controller, data processors and designated representative pursuant to article 5, paragraph 2; e) entities or categories of entities to whom or which the personal data may be disclosed, and whoever becomes aware of said data in his/her capacity as designated representative in the State’s territory, or as data controller or data processor.

3) The data subject has the right to : a) update, correct or supplement data whenever deemed necessary;

b) delete, anonymise or block data that has been processed unlawfully, including data for which retention is unnecessary for the purposes for which they have been collected or subsequently processed;

c) attest that the actions as per letters (a) and (b) have been notified to the entities to whom data was disclosed, also as far as their respective content, unless this requirement proves impossible to fulfil or involves a disproportionate use of resources in relation to the right to be protected.

4. the data subject has the right to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or to conduct market or communication surveys.

To exercise your rights pursuant to art. 7 of Leg.Decree196/2003, please contact: Venchi SpA, Via Venchi 1, 12040 Castelletto Stura (CN) or send an e-mail to: customercare@venchi.com. Through the same procedure, you may request a complete, updated list of the Data Processors.

Data Controller and Data Processor

The Data Controller is Venchi SpA, as stated in the addresses published on the website. The complete list of Data processors may be requested by contacting Venchi SpA, Via Venchi 1, 12040 Castelletto Stura (CN) or by sending an email to: customercare@venchi.com.

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